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In re Rabon

United States Bankruptcy Court for the District of Connecticut · Federal bankruptcy courts · CT · · No. 25-21127 (JJT) · memorandum opinion

Fabricated or misquoted citationscourt does not name AI

On 2026-04-03, U.S. Bankruptcy Court for the District of Connecticut denied the debtor’s contract arguments and ordered counsel to show cause separately under Bankruptcy Rule 9011 for apparently false citations. Counsel submitted a motion with 7 false quotations. The response requirement preceded any sanction decision.

Disposition
The court granted the motion for in rem relief from stay and stated that debtor’s counsel would separately be ordered to show cause over apparently false citations.
Recorded conduct
Debtor’s counsel cited two cases in the debtor’s brief; quoted language appeared in neither case and one cited case had nothing to do with the proposition asserted. — outcome: pending; actor: lawyer
Canonical record
Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

rejected any proposal that did not recognize him as the sole buyer of the Note. St.Germain blamed Daniel Malchman’s “eleventh hour tactic to get his wife and Russ named as co-assignees[,]” which St.Germain stated “kind of pissed me off[.]” 10 St.Germain, having initiated the Berkshire Bank transaction, unilaterally believed that he should own and control the Note. Attorney Liberty, however, testified that St.Germain’s loan approach was improvident and unacceptable, as it would render his clients unsecured creditors vulnerable to loss. Understandably, the risks of loss in St.Germain’s approach were too significant. As a consequence, no agreement was ever reached by St.Germain and Malchman and Russ. 11 Meanwhile, in Mark Rabon’s Chapter 7 case, the Movants moved for relief from stay under 11 U.S.C. § 362(d)(1), so as to continue the foreclosure process in the Superior Court. That motion went unopposed by the Debtor, Mark Rabon, and St.Germain and was subsequently granted. The Debtor then filed the instant case on October 24, 2025. By operation of law, the stay against the Debtor expired after 30 days because the Debtor’s prior Chapter 13 case had been dismissed within one year of the

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